CLEARTRADE COMMODITIES PRIVACY POLICY

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Your Privacy is Our Priority

ClearTrade, Inc. is committed to safeguarding the personal information that you provide us. This Privacy Policy describes how we handle and protect personal information we collect about individuals, such as you, who apply for or receive our products and services. The provisions of this notice apply to former customers as well as our current customers.

Why and How We Collect Personal Information

When you apply for or maintain an account with ClearTrade, we collect personal information about you for business purposes, such as evaluating your financial needs, processing your requests and transactions, informing you about products and services that may be of interest to you, and providing customer service. The personal information we collect about you includes:

information you provide to us on applications and other forms, such as your name, address, date of birth, social security number, occupation, assets, and income;

Information about your transactions with us;

Information we receive from consumer reporting agencies, such as your credit history and creditworthiness, and other entities not affiliated with ClearTrade; and

Information you provide to us to verify your identity, such as a passport, or received from other entities not affiliated with ClearTrade.

How We Protect Personal Information

We limit access to your personal information to those employees who need to know in order to conduct our business, service your account, and help you accomplish your financial objectives, such as providing you with a broad range of products and services. Our employees are required to maintain and protect the confidentiality of your personal information and must follow established procedures to do so. We maintain physical and procedural safeguards to protect your personal information. We do not rent or sell your name or personal information to anyone.

Disclosure to Non-Affiliated Third Parties

In order to support the financial products and services we provide to you, we may share the personal information described above with third-party service providers and joint marketers not affiliated with us, including:

financial service institutions (e.g., advisers, dealers, brokers, trust companies and banks) with whom we have joint marketing agreements, such as agreements to market financial services or products that we jointly offer, endorse or sponsor; and companies under contract to perform services for us or on our behalf, such as vendors that prepare, mail statements, transaction confirmations or provide data processing, computer software maintenance and development, transaction processing and marketing services.

These companies acting on our behalf are required to keep your personal information confidential.

Also, we may disclose personal information with non-affiliated companies and regulatory authorities as permitted or required by applicable law. For example, we may disclose personal information to cooperate with regulatory authorities and law enforcement agencies to comply with subpoenas or other official requests, and as necessary to protect our rights or property. Except as described in this privacy policy, we will not use your personal information for any other purpose unless we describe how such information will be used at the time you disclose it to us or we obtain your permission to do so.

Accessing and Revisiting Your Personal Information

We endeavor to keep our customer files complete and accurate. We will give you reasonable access to the information we have about you. Most of this information is contained in account statements that you receive from us and applications that you submit to obtain our products and services. We encourage you to review this information and notify us if you believe any information should be corrected or updated. If you have a question or concern about your personal information or this privacy notice, please contact your ClearTrade representative.

RIGHT TO OPT OUT OF INFORMATION SHARING

If you prefer that we not disclose your Personal Information to unaffiliated third parties, you may opt out of those disclosures. That is, you may direct us not to make those disclosures (other than disclosures permitted or required by law). You, however, may not opt out of Personal Information disclosed about you to your Introducing Broker (if applicable), or any service provider necessary to effect or process any transaction in your account(s) with us (if applicable). If you wish to opt out of disclosure to non affiliated third parties, you may email us at research@198.252.109.132, stating that you wish to opt out of all information sharing of your Personal Information.

JOINT ACCOUNT/PARTNERSHIP PROCEDURES

In the event you have an R.J. O'Brien account, and if your account(s) with us is for joint tenants with rights of survivorship, tenants in common, or a general partnership, any one party to the account may elect to opt out for the account. That opt out election will bind all parties to the account.

ClearTrade’s Privacy Policy

R.J. O'Brien & Associates, LLC and its affiliates (collectively, “R.J. O’Brien” or we or us) and your Introducing Broker ClearTrade, who has adopted this policy, believe in respecting the privacy and security of your personal information.

Please read this Privacy Policy carefully.

We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law.

Collection of Information

We may collect personally identifiable information (“PII”) about you from the following sources:
Information we receive from you on applications or other forms;
Information from communication and interactions that we have with you;
Information from third parties who provide consumer information or verify consumer relationships;
Information about your transactions with us, our affiliates or others;
Information we receive from a consumer reporting agency; and
Information about you that we obtain through an information collecting device from a web server.

PII includes any information by which you can be personally identified, and may include your name, address, age, date of birth, electronic mail address, occupation, employment information, telephone number, education, the kind of service provided to you, credit card number, and other similar information.

Use and Disclosure of Your Information

We may use and/or share your PII for the following reasons:
to contact you in response to your inquiries, comments and suggestions;
to contact you otherwise when necessary;
for the specific purpose for which it was volunteered;
to complete any transactions you may perform with or through us;
to be provided to R.J. O’Brien’s third parties in connection with the legitimate business purposes of R.J. O’Brien or the site;
to third parties that assist us with preparing and processing orders and statements;
as required by law or regulation, or as requested by government authorities, or for the protection of persons or property;
in connection with an acquisition, merger, restructuring, sale or other transfer involving all or any portion of the business ; and

Confidentiality and Security

We restrict access to your PII to those employees who need to know that information to provide products or services to you. We maintain physical, electronic and procedural safeguards to guard your PII.   However, due to the design of the Internet, we cannot guarantee that communications between you and our servers will be free from unauthorized access by third parties.

USA PATRIOT ACT
NOTICE TO CUSTOMERS

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.

What this means for you: When you open an account, we will ask for your name, address, date of birth and other information that will allow us to identify you. We may also ask to see your driver's license or other identifying documents.